COVID-19 Office Hours for ESG Recipients April 27, 2020 Reminders - - PowerPoint PPT Presentation
COVID-19 Office Hours for ESG Recipients April 27, 2020 Reminders A recording of todays session, along with the slide deck and a copy of the Chat and Q&A content will be posted to the HUD Exchange within 2-3 business days Event
Q&A content will be posted to the HUD Exchange within 2-3 business days
found here: https://www.hudexchange.info/homelessness-assistance/diseases/#covid-19-webinars- and-office-hours
Select the Chat icon to make a comment or ask a question. Be certain the To field is set to All Participants An orange dot on the Chat icon indicates that you have unread messages.
Chicago
(ESG-CV)
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If you are not already, get involved in the public health response immediately.
understand the sheltering and safety response for people who are COVID positive, symptomatic and at high risk of severe illness.
they are working with their local public health departments.
and quarantine options offered through non-congregate settings.
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COVID-19
monitoring
consideration for future monitoring
through local evaluation metrics
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experiencing homelessness, start housing people in unsheltered locations and congregate shelters
housing people as they exit so they don’t return to unsheltered or congregate settings
with the many other CARES Act resources
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and Written Standards.
available (if you put out a call to apply to everybody who needs help, you could be overwhelmed by requests).
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resource allocation and decision-making groups.
gender, and the intersection of race and gender). Determine where there are the greatest racial
programmatic and systems level.
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reaching and engaging with underserved and marginalized populations (e.g. YWCAs, Urban Leagues, CDCs, local NAACP chapters, communities of faith, Housing Justice Alliance local chapters)
and length of assistance, geography of placement, and returns to homelessness and monitor it by race, gender and the intersection of race and gender.
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Amend or prepare plans even before the notice or the second ESG-CV allocation–subsequent allocations will need additional amendments
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activities
All programmatic activities must either prepare for, respond to, or prevent coronavirus
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perform any other prerequisite activities as a condition for receiving shelter, housing, or services
All programmatic activities must either prepare for, respond to, or prevent coronavirus
Basic Process to Receive ESG-CV Grant Agreement
To access ESG-CV funding, communities must first complete a Substantial Amendment to their most recent Annual Action Plan in IDIS to add ESG-CV as an available resource The following five elements are required:
(PR-15 (CP); AP-12 (AAP))
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ESG-CV funding should be added as an “Other” funding source on the Sources table:
1) Click the “Add” link at the bottom-right of the table on the screen 2) For Anticipated Resource, select “Other” 3) For Other Funding Source, enter “FY2020 ESG-CV” 4) Enter total ESG-CV available and complete the rest of the screen
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Adding a new goal is not required for the first allocation, but should be updated when completing the amendment for the second allocation of ESG-CV funds If adding a new goal (as opposed to updating an existing goal):
create the new goal
Goals and Objectives screen
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use the AP-35 Projects table to add that project to the 2019 Annual Action Plan Amendment
activities (e.g., SO, ES, RRH, HP, HMIS, Admin) that will be funded
will eventually include FY 2020 allocation and ESG-CV second allocation
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Recipients do not have to: × Specify an amount for each activity, or × Identify subrecipients
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Complete the new forms using the appropriate link(s) on the AD-25/26 Administration screen Do not overwrite the 2019 forms that are already uploaded – either:
forms AND the new 2020 ESG-CV forms and re-upload; or
attachment link is empty
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Following community submission, the appropriate HUD Field Office will: 1) Review the Substantial Amendment and mark the amended plan as “Review Complete” in the eCon Planning Suite 2) Issue ESG-CV grant agreements
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Citizen Participation and Consultation requirements are:
publish how the allocation will be used on Government web site)
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If a community is simultaneously completing Substantial Amendments to both ESG-CV and CDBG-CV, then the Substantial Amendments are subject to CDBG- CV Citizen Participation and Consultation Requirements and the community will have to provide public notice and reasonable opportunity to comment for no less than 5 days
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24 CFR 576.107(a)(2)
24 CFR 576.401(b)
24 CFR 576.401(e)
24 CFR 576.106(d)(1) These waivers are not currently applicable to ESG-CV funds.
To Substantially Amend FY20 (or earlier) ESG Funds:
Participation Public Comment and Reasonable Notice (and any other applicable ESG Mega-Waiver provision(s))
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Citizen Participation Public Comment Period for Consolidated Plan Amendment
24 CFR 91.105(c)(2) and (k); 24 CFR 91.115(c)(2) and (i); 24 CFR 91.401
Citizen Participation Reasonable Notice and Opportunity to Comment
24 CFR 91.105(c)(2) and (k); 24 CFR 91.115(c)(2) and (i); 24 CFR 91.401
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Waiver of Public Comment Period for Con Plan Amendment
Waiver: Con Plan Citizen Participation Public Comment Period
Requirement Applicability Other Provisions
A CPD grantee may amend an approved consolidated plan in accordance with 24 CFR 91.505. Substantial amendments to the consolidated plan are subject to the citizen participation process in the grantee’s citizen participation plan. The citizen participation plan must provide citizens with 30 days to comment on substantial amendments. Through the end of the recipient’s 2020 program year, the 30-day minimum for the required public comment period is waived for substantial amendments Grantees must provide no less than 5 days for public comments on each substantial amendment Any recipient wishing to undertake further amendments to prior year plans following the 2020 program year can do so during the development of its FY 2021 Annual Action Plan
Suggested Recipient Documentation
1) Documentation of the need to expedite the amendment and demonstrating both publication and 5-day comment period; 2) A record of all comments received, and responses must be submitted with the amendment; 3) Copy of waiver notification sent to HUD; 4) Emergency recordkeeping policies and procedures
Waiver of Comment Period for Con Plan Amendment
Waiver of Reasonable Notice & Opportunity to Comment
Waiver: Citizen Participation Reasonable Notice
Requirement Applicability
As noted above, the regulations at 24 CFR 91.105 (for local governments) and 91.115 (for States) set forth the citizen participation plan requirements for recipients. For substantial amendments to the consolidated plan, the regulations require the recipient to follow its citizen participation plan to provide citizens with reasonable notice and
The citizen participation plan must state how reasonable notice and opportunity to comment will be given. HUD waives 24 CFR 91.105(c)(2) and (k), 24 CFR 91.115(c)(2) and (i) and 24 CFR 91.401 to allow these grantees to determine what constitutes reasonable notice and opportunity to comment given their circumstances
Waiver of Reasonable Notice & Opportunity to Comment
Citizen Participation Reasonable Notice and Opportunity to Comment Suggested Recipient Documentation
1) Policies and procedures including the definition of “reasonable notice and opportunity to comment” 2) Copy of waiver notification sent to HUD
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HMIS Lead Activities
24 CFR 576.107(a)(2)
Re-Evaluations for Homelessness Prevention Assistance
24 CFR 576.401(b)
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Housing Stability Case Management
24 CFR 576.401(e)
Restriction of Rental Assistance to Units with Rent at or Below FMR
24 CFR 576.106(d)(1)
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Requirement Applicability
ESG funds may be used to pay the costs of managing and operating the HMIS, provided that the ESG recipient is the HMIS Lead. For the 6-month period beginning on the date of the waiver memorandum (3/31/2020), the condition that the recipient must be the HMIS Lead to pay costs under 24 CFR 576.102(a)(2) is waived to the extent necessary to allow any recipient to use ESG funds to pay costs of upgrading or enhancing its local HMIS to incorporate data on ESG Program participants and ESG activities related to COVID-19
HMIS Lead Activities Suggested Recipient Documentation
1) Documentation of the need to upgrade or enhance the HMIS as a result
policies and procedures 2) Copy of waiver notification sent to HUD
Re-Evaluations for Homelessness Prevention Assistance
Requirement Applicability Other Provisions
Homelessness prevention assistance is subject to re-evaluation
participant’s eligibility need for assistance not less than once every 3 months. For up to the 2-year period beginning on the date of the waiver memorandum (3/31/2020), the required frequency of re-evaluations for homelessness prevention assistance under section 576.401(b) is waived The recipient or subrecipient must conduct the required re-evaluations not less than once every 6 months
Re-Evaluations for Homelessness Prevention Assistance
Suggested Recipient Documentation Suggested Client Level Documentation
1) Documentation demonstrating need to keep participant housed during COVID-19 pandemic 2) Copy of waiver notification sent to HUD 3) Emergency recordkeeping policies and procedures 1) A note in the files of affected clients 2) Documentation demonstrating compliance with the 6-month requirement.
Requirement Applicability
Program participants receiving homelessness prevention or rapid re- housing assistance must meet with a case manager not less than once per month, unless certain statutory prohibitions apply. For the 2-month period beginning on the date of the waiver memorandum (3/31/2020), this waiver is in effect
Suggested Recipient Documentation Suggested Client Level Documentation
1) Documentation of limited staff capacity, shelter-in-place order,
impediment 2) Copy of waiver notification sent to HUD 3) Emergency recordkeeping policies and procedures 1) A note in the files of affected clients.
Restriction of Rental Assistance to Units At or Below FMR
Requirement Applicability Other Provisions
Under 24 CFR 576.106(d)(1), rental assistance cannot be provided unless the total rent is equal to or less than the FMR established by HUD, as provided under 24 CFR Part 888, and complies with HUD’s standard of rent reasonableness, as established under 24 CFR 982.507. For the 6-month period beginning on the date
memorandum (3/31/2020), the FMR restriction is waived for any individual or family receiving Rapid Re- housing or Homelessness Prevention assistance who executes a lease for a unit The ESG recipient or subrecipient must still ensure that the units in which ESG assistance is provided to these individuals and families meet the rent reasonableness standard
Restriction of Rental Assistance to Units At or Below FMR
Restriction of Rental Assistance to Units At or Below FMR Suggested Recipient Documentation Suggested Client Level Documentation
1) Documentation that FMR limits are impeding grantee’s ability to find units for clients as a result of COVID-19; 2) Copy of waiver notification sent to HUD; 3) Emergency recordkeeping policies and procedures 1) A copy of the lease clearly displaying the date of execution; 2) A note to file noting the date of this memo and its application to the client’s lease; and 3) A completed rent reasonableness analysis.
Section 4024 of the CARES Act provides a temporary moratorium
1) that participate in certain federal assistance programs, including CoC, ESG, HOPWA 2) in dwellings for 1 to 4 families with a federally backed mortgage loan 3) in dwellings with 5 or more units (i.e., multifamily) with a federally backed multifamily mortgage loan
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Duration of Eviction Moratorium
Eviction Moratorium DOES NOT apply in the following cases:
though no extra fees or penalties can be made during this time
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What types of eviction claims and fees are prohibited?
to nonpayment of rent - for someone in a covered property
the moratorium period.
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prevention programs
homelessness due to eviction:
that apply to this moratorium
New Q&A’s posted on the HUD Exchange
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Intensive TA Workshops: CARES Act Funding Utilization
conferencing, working sessions, and individual support
Investment Planning, Housing Problem Solving
Response, ESG State Recipients
management, administrative process
https://www.hudexchange.info/programs/consolidated-plan/
https://www.hudexchange.info/programs/consolidated-plan/
https://www.hudexchange.info/program-support/my-question/
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